https://www.noxia.co.uk/field-notes/nine-point-one-billion-and-twelve-million-agreements · printed from noxia.co.uk · sources checked 24 September 2026
Field note · Advice & compliance
£9.1bn, 12.1 million agreements, and an average of £829.
A redress exercise of this size does two things at once: it moves a great deal of money, and it teaches every firm watching what a decade-old file is worth. The second lesson is the one that applies to firms who have never written a motor finance agreement.
- Advice & compliance
- Redress
- FCA
- Motor finance
- Record keeping
The short answer
On 30 March 2026 the FCA confirmed a motor finance redress scheme costing firms £9.1 billion — £7.5bn in redress and £1.6bn in non-redress costs — across 12.1 million agreements at an average of £829. Scope is agreements from 6 April 2007 to 1 November 2024 where the lender paid the broker commission. On 2 July 2026 the Upper Tribunal suspended the calculating and paying of redress while it hears four challenges; if the scheme is upheld, the FCA expects payments to begin in 2027.
On this page · 6 sections
The headline number is large enough to be abstract. The per-agreement number is not: £829 is a figure a person recognises, multiplied by twelve million people.
That £1.6 billion is the part worth staring at. It is not compensation. It is the cost of locating agreements, reconstructing what commission was paid, deciding who is owed what, and contacting people who have moved house twice since 2011.
The clock, and the part that stopped
The suspension stops the paying, not the finding. Firms must still identify complaints, gather the commission data and answer complainants who are owed nothing — by 18 November 2026 for agreements from April 2014, and by 18 January 2027 for earlier ones. That is the finding-out work the £1.6 billion pays for, and it carries on while the tribunal decides the rest.
When contact does start, a consumer has six months to respond, and the people least likely to respond are the ones the scheme most wants to reach: older agreements, more house moves, less trust in an unexpected letter about money.
Why this matters to a firm that has never sold motor finance
Because the mechanism is general, and it has now been demonstrated at scale.
A practice that was widespread and unexamined was later reassessed against a standard applied retrospectively, and the cost fell on firms in proportion to how well they could reconstruct what they had done. The firms that could produce the file argued about the merits. The firms that could not paid the administration cost of finding out — and that is the £1.6 billion.
Nothing about that is specific to car finance. It is the same argument as the audit trail note with a nine-figure number attached, and it is why the redress framework is being rebuilt at the same time.
Three things worth doing whatever you sell
- Pick a practice that is currently normal in your market and unexamined. Commission disclosure was that, once. Ask what yours is.
- Test whether you could reconstruct a 2019 file. Not the contract — the reasoning. What was disclosed, to whom, in what words.
- Price the finding, not just the paying. The scheme says that costs about a sixth as much again as the redress itself, and it is the part a firm controls today.
What this does not tell you
It does not tell you whether the scheme is right, or whether it survives. Four parties — a consumer group and three lenders — are arguing that in the Upper Tribunal, and we have no view worth publishing on it.
It also does not tell you what any individual is owed — £829 is an average across 12.1 million agreements, and averages of that kind conceal everything interesting. A consumer wanting to know their position should read the FCA's own consumer pages rather than an agency's summary, and should be wary of anybody offering to claim on their behalf for a share, since representation has already fallen from 45% to 10% of Ombudsman referrals for good reasons.
If you want the general version of the lesson, it is the board report note: four of the FCA's five criticisms there were about evidence a firm did not hold. The evidence work is the unglamorous answer, and the adoption calculator will tell you whether a system to do it pays.
Questions people actually ask
How much is the motor finance redress scheme worth?
The FCA confirmed a total cost to firms of £9.1 billion — £7.5 billion in redress to consumers and £1.6 billion in non-redress costs. Roughly 12.1 million agreements are eligible, at an average of £829 per agreement.
Which motor finance agreements are covered?
Agreements taken out between 6 April 2007 and 1 November 2024 where commission was payable by the lender to the broker are eligible for consideration under the scheme.
When will people be paid?
Under the scheme, not before 2027. On 2 July 2026 the Upper Tribunal suspended the parts that calculate and pay redress while it hears challenges from four parties, listed for 14 to 18 December 2026 or 16 to 26 February 2027. If the scheme is upheld and the judgment is not appealed, the FCA expects payments to begin in 2027.
What should a firm outside motor finance take from this?
That a widespread, unexamined practice can be reassessed later against a standard applied retrospectively, and that the cost falls in proportion to how well a firm can reconstruct what it did. The £1.6 billion of non-redress cost is the price of records kept for accounting rather than for answering questions.
Sources
- Financial Conduct Authority, “Motor finance scheme partially suspended”, 2 July 2026: the Upper Tribunal has suspended parts of the scheme on terms agreed with four challengers — Consumer Voice, Volkswagen Financial Services, Mercedes-Benz Financial Services and Crédit Agricole Auto Finance; firms need not “calculate or pay redress, or send communications about compensation owed” on the original timetable, but must still identify complaints, gather commission data and respond to consumers not owed compensation (by 18 November 2026 for agreements from 1 April 2014, 18 January 2027 for earlier ones); hearing listed for “14 to 18 December 2026 or 16 to 26 February 2027”; “If the scheme is upheld, and the judgment isn’t appealed, we expect payments under the scheme to begin in 2027.” fca.org.uk ↗ — primary; the regulator on the state of its own scheme re-checked every 30 days
- Financial Conduct Authority, “FCA confirms motor finance redress scheme”, first published 30 March 2026 — its timetable overtaken by the suspension above: total cost to firms £9.1 billion, comprising £7.5 billion redress and £1.6 billion non-redress costs; approximately 12.1 million agreements eligible; average redress per agreement £829; scope agreements between 6 April 2007 and 1 November 2024 where commission was payable by the lender to the broker; implementation periods ending 30 June 2026 for agreements from 1 April 2014 onward and 31 August 2026 for earlier agreements; firms then have 3 months to notify complainants and 6 months to contact non-complainants, with consumers having 6 months to respond; “Millions of consumers will be compensated this year, most of the rest by the end of 2027.” The page carries the 2 July notice of the suspension. fca.org.uk ↗ — primary; the regulator’s own confirmation of its own scheme. The figures stand; the timetable does not re-checked every 6 months
- Policy statement PS26/3, Motor Finance Consumer Redress Scheme, March 2026 — the rules themselves. fca.org.uk ↗ — primary re-checked every 6 months
- The reading of the £1.6 billion as the price of records kept for accounting rather than for answering, and the three things to do, are ours. We take no position on whether the scheme is correct. — our own argument, labelled as such
Checked 24 September 2026. Next scheduled check 24 October 2026. Numbers that move — leaderboards, live indices — are re-checked every 30 days; annual datasets and rules in force every six months; dated research once a year. If something here has gone stale before we got to it, tell us and we will correct it and say what changed.
Cite this note
Noxia, “£9.1bn, 12.1 million agreements, and an average of £829”, Field notes, 23 September 2026; sources checked 24 September 2026. https://www.noxia.co.uk/field-notes/nine-point-one-billion-and-twelve-million-agreements
Could you reconstruct a 2019 file? Not the contract — the reasoning.
That is the whole test and it takes an afternoon to fail. We build the record so the answer is yes without anybody reconstructing anything: what was disclosed, to whom, in what words, with a date nobody typed in later. It is the cheapest insurance against a standard nobody has applied yet.
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